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To promote transparency in prescription drug pricing and healthcare spending, The Consolidated Appropriations Act (CAA) requires group health plans and health insurance issuers offering group or individual health insurance coverage to submit detailed information about prescription drugs and health care spending to the Departments of Labor, Treasury, and Health and Human Services. The first reports, covering 2020 and 2021 calendar years, were due by December 27, 2022 and annually thereafter each June 1st. The report, known as the RxDC report, contains plan files, data files, and narrative responses and is submitted through the RxDC module in the Health Insurance Oversight System (HIOS). The next RxDC report for all group health plans is due June 1, 2024, covering 2023 calendar year data.
Employer sponsored group health plans may satisfy their reporting obligation by having a third party such as a carrier, TPA, and/or PBM submit some or all of the required information on their behalf (pursuant to a written agreement). Where an applicable third party is only providing partial information to CMS, the group health plan sponsor will be responsible for reporting the remainder of the data. Many carriers, TPAs, and PBMs have already reached out to group health plan sponsors notifying them what information they will be reporting and requesting certain plan level data to be submitted to them, such as average monthly premiums (or premium equivalents) paid by member and employer. These information requests have very tight deadlines that group health plans must adhere to. Employers who have not already heard from their carrier, TPA, or PBM should reach out to them as soon as possible to verify what files they will be reporting on their behalf as well as any information they will require from the plan sponsor to complete the reporting.
For questions and to verify reporting responsibility and information needed, please contact your carrier, TPA or PBM or feel free to reach out to your Lawley Account Executive.
Judy joined the Employee Benefits division of Lawley in March 2010 as a Compliance Specialist. Judy’s role is to provide clients with enhanced service in the areas of new and existing legislation and compliance. She works closely with Employee Benefits Consultants and Account Executives to provide clients with the tools and information to remain compliant. Judy provides timely education, guidance and conveys the requirements and intricacies of new legislation in a practical fashion.
Specifically, Judy has focused her attention on the Affordable Care Act (ACA) and possesses a thorough understanding of the continuously evolving requirements of this law.